Vietnam Crypto ML: Latest Challenges & Legal Framework 2025
Vietnam Warns Of Crypto Money Laundering: New Tactics And Control Solutions
Vietnam's crypto asset market is facing serious challenges related to money laundering activities. This warning was issued by state regulatory agencies on October 17, 2025, raising deep concerns about illegal activities and the absence of a comprehensive legal framework. In this context, Bitcoin, Ethereum (ETH), XRP, and many other crypto assets continued their downward trend, reflecting market reactions to this information.
Vietnam Strengthens Crypto Money Laundering Control: Latest Legal Context
Warnings From Regulators And Key Legal Developments
On October 17, 2025, a representative from the State Securities Commission (SSC) publicly identified various signs of money laundering behavior in Vietnam's crypto asset market. This event followed a series of important workshops and discussions on October 15 and 16, 2025, co-organized by the State Bank of Vietnam (SBV) and the SSC.
The main purpose of these events was to disseminate Circular No. 27/2025/TT-NHNN and Resolution 05/2025/NQ-CP, and to update the results of the National Risk Assessment on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT). Circular 27/2025/TT-NHNN, effective from November 1, 2025, guides the implementation of the Law on Anti-Money Laundering. Meanwhile, Resolution 05/2025/NQ-CP, issued on September 9, 2025, stipulates the pilot program for the crypto asset market in Vietnam, opening a legal corridor for this experimental phase. The Vietnamese Government has committed to the Financial Action Task Force (FATF) to implement the National Action Plan on AML and CFT.
Deputy Prime Minister Ho Duc Phoc, Head of the National Steering Committee on AML/CFT, has requested the SBV to coordinate closely with relevant ministries and agencies to complete the legal framework and enhance public awareness of money laundering risks.
Unmasking Sophisticated Crypto Money Laundering Tactics In Vietnam
Key Identified Methods
Mr. To Tran Hoa, Deputy Head of the Securities Market Development Department at the SSC, pointed out several common money laundering tactics in the crypto asset market. These methods demonstrate the sophistication and adaptability of criminals in a new technological environment:
• Exploiting lax verification systems: Perpetrators frequently use fake documents or exploit the allowance of anonymous transactions on some exchanges to easily transfer illicit funds.
• Mixing crypto assets: The act of 'mixing' illicit crypto assets with legitimate ones is extremely difficult to identify and trace. Service providers often only identify ownership without verifying asset origin, creating loopholes for this activity.
• Legitimization via 'privacy coins': Converting value to privacy coins like Monero or Zcash to conceal the origin, then swapping them with legitimate crypto assets.
• Chain-hopping/Cross-chain Bridge transactions: Using cross-chain bridges to create multiple complex transaction trails, making it difficult to trace the origin of funds.
• Transactions via P2P 'black markets': Exploiting direct peer-to-peer transactions through 'black markets' (often private social media groups) to buy and sell crypto assets with cash. These transactions rely on personal trust rather than official verification, with values potentially reaching millions of USDT daily.
• Creating 'clean' projects for money laundering: Criminals create seemingly 'clean' crypto projects, then use illicit crypto assets to purchase them. Once the funds are legitimized, they 'collapse' the project to erase traces.
• Dividing transactions: Executing many small-value transactions (e.g., 1,000 - 2,000 USD, below the 10,000 USD alert threshold) to avoid detection by automated monitoring systems.
Reaction of Vietnam's Crypto and Stock Markets (October 17, 2025)
Widespread Price Declines
As of 8:00 AM on October 17, 2025 (Vietnam time), the global cryptocurrency market saw price declines across most coins. Bitcoin dropped 2.27%, trading around 108,818 USD (at one point falling to 107,563 USD), with a market capitalization of 2.17 trillion USD. Ethereum (-2.05%), Binance Coin (-2.60%), and XRP (-2.46%) also fell, while Solana (-4.67%), Dogecoin (-3.86%), and Cardano (-3.24%) experienced sharper declines. This downtrend is attributed to news regarding geopolitical tensions involving China.
Concurrently, the Vietnamese stock market also faced pressure. In the morning session of October 17, 2025, the VN-Index dropped more than 13 points (0.77%) to 1,753.32 points, with strong selling pressure from large-cap stocks, especially the 'Vingroup group' (VIC, VHM, VRE, VPL) and banking stocks.
Tight Legal Framework And Money Laundering Prevention Solutions
Crypto Asset Market Pilot Program
Vietnam is implementing a 5-year pilot program for the crypto asset market, limiting a maximum of 5 licensed service providers. These organizations must have a charter capital of at least 10 trillion VND (of which 65% must be domestic capital) and strictly adhere to regulations on security, asset custody, and AML.
A critical clause states that 6 months after the first organization is licensed, Vietnamese investors trading crypto assets not through these licensed organizations will be dealt with according to regulations, aiming to tighten control and channel activities through official channels.
Risk-Based Management Principles And Regulations In Circular 27
Circular 27/2025/TT-NHNN emphasizes the principle of risk-based management, requiring organizations to periodically assess money laundering risks, establish customer identification and verification procedures (including for non-account holders or infrequent transactors), and monitor business relationships to ensure transactions align with legitimate fund sources.
Real-World Cases And Requirements For Transactions On Licensed Exchanges
There have been numerous documented cases of crypto-related fraud and money laundering in Vietnam, notably the case involving Mr. Nguyen Hoa Binh ('Shark Binh') with the AntEx project, which defrauded thousands of billions of VND, or the Wingstep project that raised 200 billion VND. Perpetrators often convert stolen money into crypto assets via P2P transactions on international exchanges and constantly change information to evade investigation.
Resolution 05/2025/NQ-CP mandates that crypto asset transactions must be conducted on licensed pilot exchanges to tighten management. Furthermore, the national risk assessment on money laundering also indicates high risks in the banking and real estate sectors, with predicate offenses such as gambling, fraud, and corruption. Deputy Prime Minister Ho Duc Phoc has called for increased AML measures in transactions on real estate and crypto exchanges.
Clearly identifying money laundering tactics and implementing strict control measures are essential to protect investors, ensure monetary security, and promote the transparent and sustainable development of Vietnam's digital financial market.
Conclusion: Towards A Transparent And Sustainable Digital Financial Market
The warnings from the State Securities Commission and the State Bank of Vietnam on October 17, 2025, along with the issuance of new legal documents such as Circular 27/2025/TT-NHNN and Resolution 05/2025/NQ-CP, indicate that the Vietnamese Government is urgently completing its legal framework to manage and control money laundering risks in the crypto asset market. These actions are crucial steps towards a safer and more reliable digital financial market.
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